verification report for: proponent: prepared for: versionfor facilities: description of compliance...

Ember Resources Instrument Air Conversion at Strathmore (1665-4576) August 2018

Verification Report for: Ember Resources Instrument Air Conversion at Strathmore (1665-4576)

Proponent:

Ember Resources Inc.

Prepared by:

Brightspot Climate Inc.

Prepared for:

Alberta Climate Change Office

Version: Final

Date:

August 22, 2018


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Table of Contents 1.0 Summary – Offset Project ...................................................................................... 4 1.1 Summary – Facility ......................................................................................................... 7 2.0 Introduction .......................................................................................................... 8

2.1 Objective .............................................................................................................. 8 2.2 Scope .................................................................................................................. 9 2.3 Level of Assurance ................................................................................................. 9 2.4 Criteria .............................................................................................................. 10 2.5 Materiality .......................................................................................................... 10

3.0 Methodology ....................................................................................................... 10 3.1 Procedures ......................................................................................................... 11 3.2 Team ................................................................................................................. 23 3.3 Schedule ............................................................................................................ 25

4.0 Results ............................................................................................................... 25 4.1 Assessment of Internal Data Management and Controls ........................................... 25 4.2 Assessment of GHG Data and Information .............................................................. 26 4.3 Assessment against Criteria .................................................................................. 29 4.4 Evaluation of the GHG Assertion ............................................................................ 34 4.5 Summary of Findings ........................................................................................... 34 4.6 Opportunity for Improvement ............................................................................... 36

5.0 Closure .............................................................................................................. 36 5.1 Verification Statement ......................................................................................... 36 5.2 Limitation of Liability............................................................................................ 36 5.3 Confirmations ..................................................................................................... 37

6.0 References ......................................................................................................... 37 Appendix A: Final Verification Plan and Sampling Plan ............................................................. 38 Appendix B: Statement of Qualifications ................................................................................ 64 Appendix C: Findings and Issues .......................................................................................... 66 Appendix D: Statement of Verification ................................................................................... 68 Appendix E: Conflict of Interest Checklist .............................................................................. 71 Appendix F: Supplemental Diagrams/Tables/Figures ............................................................... 74

List of Tables Table 1: Risk Assessment .................................................................................................... 15 Table 2: Findings of Data Integrity Verification Procedures ...................................................... 26 Table 3: Findings of GHG Data and Information Verification Procedures..................................... 27 Table 4: Findings of Criteria Verification Procedures ................................................................ 30 Table 5: Offset Criteria Assessment ...................................................................................... 33 Table 6: Summary of Findings.............................................................................................. 35 Table 7: Confirmation Findings ............................................................................................. 37 Table 8: Detailed Findings and Issues Log ............................................................................. 67 Table 9: Supporting Documentation Reviewed ....................................................................... 75


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Instructions are in italics throughout and should not be deleted when report is complete. Some instructions are specific to the verification of facilities and for offset projects. The document is not restricted but do not alter the format, the layout, the headings or the overall ‘look and feel’ of the document. If if is more usefule to paste information outside of the text box, use the empty line just below the text box to drop text or tables int. This should not change the headings or the formats. There are several dropdown boxes in the document that must be completed.

• Complete report in Verdana 10pt font (no italics). • After the report is complete, right click the table of contents and ‘update field’ which will

update page numbers in Table of Contents. • If an instruction only applies to facilities or only applies to offsets indicate ‘not applicable’. • Appendix F is available for additional tables, diagrams etc.


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1.0 Summary – Offset Project

Item Description

Project Title

Enter project title (must match the registry project title)

Ember Resources Instrument Air Conversion at Strathmore Phase 1

Project Description

Provide a brief description of the project and baseline conditions.

The Responsible Party has installed an instrument air system at its Strathmore 09-27-024-25W4 compressor facility, located in Alberta. The Project reduces emissions of greenhouse gases by retrofitting natural gas-driven instrumentation with air-driven instrumentation. The new air compression system (air compressors, air driers, air receivers, piping and associated infrastructure) is electric-driven and is connected to the Alberta Interconnected Electricity System.

Metered air flow data is collected from the project site using a centralized SCADA system. Natural gas composition is analyzed annually in a third-party laboratory.

Project Location

Include the latitude and longitude for each unique location or installation. Include legal land location if applicable and other information identifying the unique location.

Site Name Location (LSD) Coordinates

Strathmore 09-27-024-25W4 51.076, -113.403

Project Start Date

Enter the project start date.

January 1, 2010

Offset Start Date

Enter the start date for offset credit generation.

January 1, 2010

Offset Crediting Period

Enter the offset crediting period, including the offset start date. Include day, month year.

January 1, 2010 - December 31, 2017

Reporting Period

Enter the reporting period being verified.

August 1, 2016 – December 31, 2017


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GHG Assertion (Actual Emission Reductions/Sequestration Achieved)

Enter the actual emissions reductions / sequestration for the reporting period. Enter serial numbers if available.

355 tonnes CO2e

Protocol

Indicate the relevant protocol (if applicable)

Quantification Protocol for Instrument Gas to Instrument Air Conversion in Process Control Systems, Version 1.0, October 2009

Ownership

Enter offset project owner.

Ember Resources owns 100% of the Strathmore 09-27-024-25W4 facility and is the sole owner of the emission offsets from the instrument gas to air conversion project.

Project Activity

State how the project activity meets the eligibility requirements

The project must meet the eligibility criteria stated in Part 3, Section 16 of the Carbon Competitiveness Incentive Regulation (CCIR). In order to qualify, emission reductions must:

• Occur in Alberta; • Result from an action taken that is not otherwise

required by law at the time the action is taken; • Result from actions taken on or after January 1,

2002; • Occur on or after January 1, 2002; • Be real, demonstrable, quantifiable and verifiable; • Be quantifiable and measurable, directly or by

accurate estimation using replicable techniques.

The verification included an evaluation of these criteria as well as the specific applicability criteria described in the Protocol. The results of this analysis are described in Section 4.3 of this report.

Project Contact

Enter contact name, company name, mailing address, phone number and email address.

Steve Gell, P. Eng. Ember Resources Inc. The Devon Tower, 800-400 3rd Ave SW Calgary, AB T2P 4H2 +1 (403) 698-8983 [email protected]

Verifier

Verifier name, verifier’s company name, address, phone number email etc.

Aaron Schroeder, P.Eng. Brightspot Climate 225 West 8th Avenue, Suite 300 Vancouver BC V5Y 1N3 +1 (604) 353-0264 [email protected]


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Verification Team Members

Include verification team members, roles, training, training dates and qualifications.

Aaron Schroeder, P.Eng. Roles: Lead Verifier and Designated Signing Authority Training: Greenhouse Gas Verification – ISO 14064- 3, Canadian Standards Association, 2012; Instructor – Greenhouse Gas Verification – ISO 14064-3, University of Toronto, 2015 – 2018

Jeanna Brown, P.Eng. Role: Associate Verifier Training: GHG Validation and Verification, ISO 14064-3, University of Toronto, October 2017

Chris Caners, P.Eng. Role: Peer Reviewer Training: Greenhouse Gas Verification – ISO 14064-3, Canadian Standards Association

Designated Signing Authority

Enter the designated signing authority for this verification.

Aaron Schroeder, P.Eng. Brightspot Climate 225 West 8th Avenue, Suite 300 Vancouver BC V5Y 1N3 +1 (604) 353-0264 [email protected]

Verification Strategy

Describe the verification strategy used for the verification, including rationale for the approach. Note, if a controls reliance is used, provide justification for how the project is able to support this approach.

The verification strategy applied a largely substantive approach. The verification procedures, which are detailed later in this section, were designed to test the activity data directly, wherever practical. By applying this approach, the verification did not rely heavily on the Responsible Party’s controls, but rather relied on the substantive evidence collected from verification procedures that reviewed metered data, data directly from invoices and independent laboratory reports, for example.


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1.1 Summary – Facility

Item Description

Facility Name and Company Name

List company name and facility name.

Not applicable for offset verification reports

Facility Description

Provide a brief description of the facility.


Baseline Emissions Intensity Description

List the approved BEIA and the baseline years.


Reporter Contact

Enter contact name, company name, mailing address, phone number and email address.


GHG Assertion

Enter the actual emissions, production, emissions intensity and the reduction target being verified.


Verifier

Verifier name, verifier’s company name, address, phone number email etc.


Verification Team Members

Include verification team members, roles, training, training dates and qualifications.


Designated Signing Authority

Enter the designated signing authority for this verification.



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2.0 Introduction Provide an introduction to the facility or project, the verification, and the background.

For Offset Project: summary of offset project baseline, changes to the baseline since project start date and summary of changes at the project since the offset project start date or baseline period.

For Facilities: Description of compliance or baseline report, facility/project boundary, facility identification information, GHG historical performance, summary of changes since the baseline or since the last compliance report.

Summary of Offset Project Baseline

This Instrument Air Conversion Project reduces greenhouse gas emissions from a natural gas compression facility through the installation of instrument air compressors and related infrastructure to retrofit the existing natural gas-driven pneumatic instrumentation system for process control. The use of compressed air to operate the pneumatic system eliminates the venting of natural gas (primarily methane) that occurred in the baseline scenario from the use of pressurized natural gas to operate the pneumatic instrumentation system.

Summary of Changes

The Responsible Party’s Offset Project Report (OPR) indicates that there have been no changes to the project boundaries and no equipment changes during the reporting period.

A change of ownership occurred prior to the reporting period. The Instrument Air Conversion at Strathmore Phase 1 is now 100% owned and operated by Ember Resources.

Operational changes at the Strathmore Phase 1 facility have significantly reduced the consumption of instrument air since April 2016, and therefore the GHG emission reductions generated from the Project have decreased.

A change in gas composition occurred at the Strathmore Phase 1 facility during the reporting period. In August 2017, the Facility began received a richer gas supply from a third party. The gas composition used in the quantification was therefore updated to reflect the new gas analysis from August 1, 2017 forward.

Through the course of the verification, the changes described above were confirmed. No additional changes to the project boundary, emission sources, measurement and monitoring or quantification methodologies were found.

2.1 Objective Describe the objective of the verification (should include expressing an opinion).

The objective of the verification is as follows:

• to issue a verification statement on whether the GHG assertion is without material discrepancy;

• to issue a verification report that provides details of the verification activities; and • to complete the “confirmations” activities defined in the Alberta Climate Change Office

Standard for Validation, Verification and Audit, Section 5.1.3.


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2.2 Scope Define the scope in terms of: geographical, organizational, activities and processes, sources, sinks, categories and greenhouse gases included (considering the completeness of the inventory), GHG assertion time period.

For offset verifications: include the serial range (i.e. XXXX-XXXX-XXX-XXX-XXX-XXX to XXXX-XXXX-XXX-XXX-XXX-XXX) if assigned (i.e. in the case of government verification a serial range will be available, otherwise not applicable).

For Facilities: ensure all specified gases and source categories are evaluated. Include list of negligible emission sources and justification for Emission Performance Credits (EPCs). Include listing of end products.

Project Name: Ember Resources Instrument Air Conversion at

Strathmore Phase 1

Serial Range: To be assigned at registration.

Geographic Boundary: The Strathmore Phase 1 compressor station is located at 09-27-024-25 W4M. The instrument air conversion project is entirely located within the compressor station lease site.

Physical Operations: Natural gas processing and compression Pneumatic devices and controllers

Emission Sources: Instrument Air Conversion

§ B7: Vented Fuel Gas § B10: Fuel Extraction and Processing § P6: Air Compression

IPCC GHGs Emitted/Removed: Carbon Dioxide (CO2)

Methane (CH4)

Nitrous Oxide (N2O);

remaining IPCC GHGs were not emitted in the baseline or project condition.

Reporting Period: August 1, 2016 – December 31, 2017

2.3 Level of Assurance The verification was conducted to a reasonable level of assurance.

Choose type of verification from the dropdown box above.

Provide explanation on level of assurance.

The Standard for Validation, Verification and Audit, Version 2.0, June 2018 requires that verifications must be designed and completed to a reasonable level of assurance.


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2.4 Criteria Outline the program criteria used and relevant supporting documentation (acts, regulations, protocols, standards, guidance documents, project documentation etc).

The program criteria used and relevant supporting documentation is as follows:

• Climate Change and Emissions Management Act • Carbon Competitiveness Incentive Regulation (255/2017) • Standard for Greenhouse Gas Emission Offset Project Developers, Version 2.0, July 2018 • Standard for Validation, Verification and Audit, Version 2.0, June 2018 • Quantification Protocol for Instrument Gas to Instrument Air Conversion in Process

Control Systems, Version 1.0, October 2009

2.5 Materiality Define the materiality of the verification.

The materiality threshold is defined in the Standard for Validation, Verification and Audit, Version 2.0, June 2018. For this verification, the materiality threshold is 5%.

3.0 Methodology Statement that the verification is performed according to ISO 14064-3.

Summary of the assessments/tests/reviews/evaluations that were conducted during the verification.

This verification was designed and completed according to the requirements of the ISO 14064-3 Standard.

The following verification activities (assessments/tests/reviews/evaluations) were conducted through the course of this verification. The specific verification activities that were conducted are detailed in the Verification Plan, which is appended to this report. They are also listed with the verification findings throughout section 4 of this report.

• Observations: the site visit included a tour of the project site to observe emission sources, metering, and data systems used for recording metered quantities;

• Review of documentation: documentation supporting the activity data was reviewed, including review of any manual transcription that was applied between documents and the emission quantification software, meter calibration reports were reviewed for completeness and to identify any metering issues;

• Recalculation: the emissions reduction was recalculated using metered data and original data sources and by applying the quantification methodologies stated in the Responsible Party’s Offset Project Report; the methods for calculating any averages used in the emission quantification were recalculated and evaluated for accuracy and appropriateness;

• Inquiry: the site visit included an interview of operations and instrumentation personnel; • Analytical procedures: a year-over-year comparison of overall emissions offsets was

performed.


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3.1 Procedures Description of how the verification was conducted including: description of the nature, scale and complexity of the verification activity, confidence and completeness of the responsible party’s GHG information and assertion, assessment of GHG information system and its controls, assessment of GHG data and information, assessment of GHG information system and controls, assessment against criteria, evaluation of the GHG assertion.

The verification strategy applied a largely substantive approach. The verification procedures, which are detailed later in this section, were designed to test the activity data directly, wherever practical. By applying this approach, the verification did not rely heavily on the Responsible Party’s controls, but rather relied on the substantive evidence collected from verification procedures that reviewed metered data, data directly from invoices and independent laboratory reports, for example.

Regarding the scale and complexity of the verification procedures, the verification risk assessment was leveraged to design verification activities appropriate to address the inherent, controls and detection risk evaluated in relation to each activity data and boundary condition. In most cases, these verifications involved review of documentation, recalculation or analytical procedures designed to produce verification evidence to support the accuracy, completeness and consistency of the information. All activity data and boundary conditions were evaluated through the verification risk assessment and verification activities were designed and completed commensurate with the verification risk assessed.

In a similar way, the data integrity, quantification methodologies and quantification itself were assessed through the verification risk assessment. Verification procedures were designed and completed to address each of these key areas.

Verification evidence was developed from each of these verification activities, which was used to establish a verification conclusion regarding the GHG information systems, the Responsible Party’s controls and ultimately, the GHG Assertion.

Describe steps of the verification including planning, assessment, site visit, off-site verification, and report preparation.

The verification was conducted according to the ISO 14064-3 standard, which establishes four primary phases of a greenhouse gas verification as described in this section. The relevant sections from the ISO standard are noted below.

Agreement (ISO Section 4.3)

The verification level of assurance, objectives, criteria, scope and materiality was affirmed in the contract for services and re-affirmed during a verification kickoff meeting.

A conflict of interest review was conducted prior to beginning work and monitored throughout the verification. A conflict of interest statement is appended to this report.

Internally, Brightspot Climate began documenting the verification upon contract signing. All documentation related to the verification will be maintained for a period of seven years following the date of the verification statement.


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Approach (ISO Section 4.4)

Brightspot Climate conducted an initial review of the Project’s greenhouse gas information, primarily by reviewing the reports and the Offset Project Plan. Brightspot Climate prepared a verification risk assessment based on this information, evaluating:

a) the inherent risks of discrepancies for each variable used to calculate each emission source and the general greenhouse gas reporting system;

b) the risk that the Responsible Party’s controls are insufficient to detect and prevent each inherent risk from causing a discrepancy in the GHG assertion; and

c) the potential magnitude of each inherent and control risk described above resulting from the contribution of the associated emission source.

This information was used to develop an appropriate verification procedure for each identified risk. Each procedure was designed to reduce the probability that the verification would not detect a discrepancy that has not been corrected by the Responsible Party’s controls. The tolerable error for each emission source is stated in the verification risk assessment.

Generally, a substantive approach was applied to the verification. Therefore, the verification procedures relied more heavily on data analysis than on controls testing.

Verification Plan

Brightspot Climate developed a Verification Plan that documents the level of assurance, verification objective, verification criteria, verification scope, and materiality. Additionally, the Verification Plan provides general description of the Project, documents operational and organizational changes that have occurred since the previous verification, explains the Project’s control environment, and describes the safety requirements of the site visit.

The results of the verification risk assessment and the verification procedures (including the sampling plan) has been included in the Verification Plan, but will not be disclosed to the Responsible Party until the final Verification Statement is issued.

Assessment (ISO Sections 4.5 – 4.7)

The verification procedures consist primarily of tests, analysis and review focused on the following six critical areas:

a) The completeness and relevance of emission sources included in the GHG Assertion;

b) The consistency of the emission sources and quantification methodologies between the Protocol, the Offset Project Plan, Offset Project Report and the tools used to quantify the emission reduction;

c) The accuracy and level of transparency of measured and estimated data sources, data integrity of electronic and manual data transfers and transcription between data systems and the GHG calculation;

d) The accuracy of the GHG emissions reduction calculations;

e) The completeness, accuracy and transparency of information presented in the Offset Project Plan and Offset Project Report documents, including the implementation of stated methodologies and emission factors in the quantification of emissions reductions; and

f) The accuracy of transcription of final calculated values into the GHG Assertion, including the “confirmations” required by ACCO as described in the ACCO Standard for Validation, Verification and Audit document.

The principles defined in the preceding six areas are defined in ISO 14064-1 (accuracy, completeness, consistency, relevance and transparency).


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Site Visit

A site visit was conducted on December 5, 2017 by Jeanna Brown of Brightspot Climate. The site visit included observation of the emission sources, metering and data systems used for recording metered quantities. The following Responsible Party staff were interviewed regarding various aspects of the project:

• Jamie Callendar, Consultant • Jim Weleschuck, Instrument Technician, Ember Resources

Further details of the verification activities that were conducted on site, including observations and inquiries, are provided in Section 4 of this report.

Verification Procedures

The remainder of the verification procedures was conducted through a desk review following receipt of the draft GHG Assertion.

Through the course of the assessment phase of the verification, Brightspot Climate issued questions and requests for additional documentation and data. These requests were consolidated in a simple electronic tracking document to maintain a common record of communication.

The Responsible Party had the opportunity to address any issues that were raised through the course of the verification before they were documented as discrepancies in the Verification Report.

Evaluation and Statement (ISO Sections 4.8 – 4.9)

Following the completion of all verification procedures and consideration of all information received from the Responsible Party, the verifier was tasked with concluding whether the GHG assertion is without material discrepancy and whether the verification reviewed sufficient and appropriate evidence to support a reasonable level of assurance.

If any outstanding discrepancies remained, their materiality would have been calculated according to ACCO guidance such that both the aggregate net quantitative error and the absolute quantitative error could be reported. In such circumstances, qualitative discrepancies would be evaluated based on the potential impact on the GHG assertion and the potential impact on the Intended User’s ability to use the reported information.

Peer Review

The independent Peer Reviewer conducted a complete review of the verification. The peer review process examined:

a) The completeness of the verification risk assessment; b) The appropriateness of the verification procedures considering the inherent and control

risks identified in the verification risk assessment; c) The appropriateness of any sampling conducted in each of the verification procedures; d) The completeness of each verification procedure, including the verifiers documentation

of work completed; e) Closure of any issues raised by the verifier through the course of the verification; f) The sufficiency and appropriateness of all evidence reviewed through the verification to

support a reasonable level of assurance; and g) A review of the final Verification Statement and Conflict of Interest Statement.


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Verification Report

The Verification Report includes a Verification Statement, Statement of Qualifications, Conflict of Interest Statement and a report on the findings of the verification. The final Verification and Sampling Plan has been appended to the Verification Report, including the results of the verification risk assessment.

Describe how the risk based approach was implemented in the sampling plan. Identify categories of risk including inherent risk, and detection risk (organization and verifier). Include the Verification Plan with the Sampling Plan in Appendix A. Paste the risk assessment table in this section.

Verification risk is defined as the risk of an incorrect verification conclusion. It can be calculated as the product of

• The Project’s inherent risks; • The Responsible Party’s control risks; and • The detection risks associated with the verifier’s verification procedures.

Inherent Risk × Control Risk × Detection Risk = Verification Risk

The verifier cannot affect the inherent risk or the control risk. Therefore, to reduce the overall verification risk and reach the agreed level of assurance (defined in the verification scope), the verifier must design verification procedures that reduce the detection risk.

Each inherent and control risk was provided with the risk score (high/medium/low). The risk analysis of inherent and control risks considers both the magnitude of the activity data or inventory component on the overall GHG assertion as well as the probability that the risk will result in a discrepancy, as assessed by the verifier.

Important note: The verification strategy for this verification is to use substantive tests instead of control tests wherever possible. Substantive tests are designed to focus on directly testing activity data or inventory components and their associated inherent risks. Control tests are designed to focus on testing the Responsible Party’s controls and if the test is successful, relying on the Responsible Party’s control. Therefore, control tests indirectly test activity data or inventory components.

Each verification procedure listed in the following table denotes if the procedure is a substantive or control test.


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Table 1: Risk Assessment

Activity Data/ Inventory Component

Inherent Risk Control Risk Max Detection Risk

Designed Detection Risk

Description of Verification Procedure

Verification Risk

Protocol Applicability Requirements

Functional equivalence must be demonstrated

Relevance (high)

Level of service may have changed between the baseline and project conditions.

The Responsible Party does not have a control specifically designed to address this inherent risk.

Low Low Substantive test: Observe operations and interview operations staff during site visit to determine level of service provided by project implementation.

Low

Project must be a conversion (not a greenfield or end-of-life replacement)

Relevance (high)

Project may have been implemented at greenfield sites or as end-of-life replacement.


Low Low Substantive test: Observe operations during site visit to determine if project was implemented as a retrofit and not as an end-of-life replacement.

Low

An inventory of devices must be maintained

Completeness (medium)

The inventory of devices may be incomplete.


Medium Medium Substantive test: Observe devices during site visit and compare against project inventory to evaluate completeness.

Medium


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Verification Risk

Demonstrate compliance with Section 8.7 of Directive 60 related to fugitive emissions management prior to project implementation


A leak detection and repair program may not have been implemented at all project sites.

Control: The project developer has implemented a management system for leak detection and repair.

Control Risk: This system may not have been implemented or maintained at all project sites (low).

Medium Medium Control test: Review the project developer’s management system for leak detection and repair to determine if system is complete for all sites and has been maintained through the reporting period.

Low

Protocol may be applied to chemical injection pumps.

N/A N/A N/A N/A Not applicable for this project.

N/A

The project must meet the requirements of the Alberta Offset System

Relevance (high)

The project may not have met the requirements of the Alberta Offset System.


Low Low Substantive test: Evaluate the project developer’s evidence regarding the general requirements of the Alberta Offset System.

Low


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Verification Risk

Project developer must establish the ownership of the emission reduction for each site within the aggregated project

Completeness (high)

Ownership may not be established with documentation for all sites within the aggregated project.


Low Low Substantive test: Review ownership documents for each project site within the aggregated project.

Low

Protocol Flexibility

Site specific emission factors may be applied


N/A

Baseline and project metering may be extended beyond one year.

Accuracy (medium)

Project metering is continuous through the reporting period. Undetected leaks may overstate the emission reduction.

Control: Project developer has implemented a leak detection and repair program at the project sites, as required by the Protocol.

Control Risk: This system may not have been implemented or maintained at all project sites (low).

Medium Low See verification procedure regarding leak detection and repair in the “Protocol Applicability Requirements” section, above.

Low


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Verification Risk

Use of instrument counts and vent rates may be used to estimate baseline emissions.


N/A

Flaring may be used to destroy captured vent gas


N/A

Implementation of instrument air conversion at multiple facilities.


The project aggregates installations at multiple project sites. The data and documentation may not be complete for all sites.


Medium Low Substantive test: Evaluate the completeness of the required data and documentation for all project sites included in the aggregated project.

Low

Quantification Data

Air compressor equipment nameplate capacity

Accuracy (low)

The recorded air compressor nameplate capacity may be inaccurate.


High Medium Substantive test: Observe the nameplate information for the air compressors during the site visit and review supporting documentation.

Low


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Verification Risk

Metered compressed air volume

Accuracy (high)

The metered compressed air volume may be incorrect if meters are not properly maintained.

Control: The Responsible Party has implemented a meter maintenance program that includes periodic meter calibration.

Control Risk: The maintenance program may not be operating effectively (low).

Low Low Controls test: Review meter calibration reports to determine if the meter maintenance program is operating effectively.

Low

Methane concentration in gas

Accuracy (low)

Reported gas compositions may not accurately represent the gas composition or may be incorrectly transcribed into the emission reduction calculation.

Control: Gas analysis is conducted by an independent lab. An internal process is used to validate results.

Control Risk: Validation process may not be properly implemented or transcription errors may be introduced (low).

High Low Substantive test: Analyze gas compositions for significant fluctuations or abnormal gas concentrations. Confirm the accurate transcription of the gas analysis into the emission reduction calculation.

Low


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Verification Risk

Completeness (low)

The gas compositions may not include a valid gas composition for each period at the required frequency.


High Medium Substantive test: Review completeness of gas composition data.

Low

Reference density of methane at STP conditions

Accuracy (low)

The density of methane applied in the calculation may not represent the density at STP conditions.


High Low Substantive test: Compare the density of methane applied in the calculations to the reference value provided in the relevant reference documents.

Low

Alberta electricity grid factor

Accuracy (low)

The Alberta electricity grid factor applied in the calculation may be incorrect.


High Low Substantive test: Compare the Alberta electricity grid factor applied in the calculations to the reference value provided in the relevant reference documents.

Low


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Verification Risk

Emission Quantification and Reporting

Application of the approved quantification protocol

Accuracy (high)

The project developer may not have implemented approved quantification methodologies or applied additional methodologies.

Control: Responsible Party has developed an Offset Project Plan that is intended to conform to the requirements of the approved quantification protocol.

Control Risk: The protocol requirements may not have been implemented correctly (medium).

Medium Low Controls test: Compare the methodologies described in the Responsible Party’s Offset Project Plan to the methodologies described in the approved quantification protocol.

Low

Substantive test: Recalculate the emission reduction using original metered data and methods described in the approved quantification protocol.

Low


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Verification Risk

Quantification of emission reduction

Accuracy (high)

Emission reduction calculation may contain arithmetic errors.


Low Low Substantive test: Recalculate the emission reduction using original metered data.

Low

Data Integrity

Activity data and emission factor data integrity

Accuracy (high)

Data may not have been accurately transferred between electronic systems and calculation sheets.

Control: The Responsible Party uses electronic data transfers whenever possible to maintain data integrity.

Control Risk: Electronic data transfers may result in errors or may not be available for all data (medium).

Low Low Controls test: Analyze all metered data for abnormal data (zeros, missing data, values outside range).

Low

Substantive test: Recalculate the complete emission reduction using original data.

Low


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Verification Risk

Transcription of final emission reduction into Offset Project Report

Accuracy (high)

Final emission reduction may not have been transcribed accurately from calculation spreadsheets into the Offset Project Report.


Low Low Substantive test: Compare the final emission reduction quantity reported by the Responsible Party to the quantity reported in the Offset Project Report. Also, compare these quantities to the recalculated quantity in previous verification procedures.

Low

3.2 Team List verification team members including peer reviewer(s).

Describe the qualifications and training of the team members and peer reviewer(s) including dates of training and certifications.

For Offsets: fill in the sample Statement of Qualification provided and included in Appendix B.

For Facilities: include the Statement of Qualifications from the facility compliance form in Appendix B.

ISO 14064-3 defines sixteen subject matter areas in which the verifier should demonstrate familiarity (see ISO 14064-3, Section A.2.2.3). The verification team has competencies in each of these sixteen subject matter areas.

Lead Verifier: Aaron Schroeder, P.Eng.

Aaron Schroeder will be the Lead Validator and Designated Signing Authority. His extensive experience quantifying and verifying greenhouse gas emissions satisfies all sixteen subject matter areas defined in the standard.

Biography: Aaron Schroeder has eleven years of professional experience analyzing, quantifying and verifying greenhouse gas emissions in North America. Prior to forming Brightspot Climate Inc. in 2015, Aaron worked for several years leading a team of fifteen greenhouse gas verification and policy analysts across Canada with ICF International. He provided leadership for this team and led the development of ICF’s standardized verification


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process, conformant with ISO 14064-3. In 2012, ICF’s verification process was accredited by the American National Standards Institute (ANSI).

Mr. Schroeder’s hands on experience conducting greenhouse gas verifications includes numerous engagements for oil and gas extraction and processing, refining, pipeline, electricity generation and petrochemical facilities. Additionally, he has conducted verifications of emission reduction projects in industrial facilities, renewable energy, waste management and agriculture. He is sought after for his expertise devising strategies to bridge the gap between theoretical and practical implementation of methodologies for quantifying, reporting and verifying.

In 2014, the University of Toronto engaged Mr. Schroeder to instruct professional development courses on greenhouse gas inventory and project quantification, reporting and verification. Since 2014, Mr. Schroeder has instructed several of these courses in live, two-day sessions and on-line instruction as a sessional lecturer through the university’s School of Environment. Additionally, Mr. Schroeder has worked with the School of Environment to re-write and update the courses.

Training: Greenhouse Gas Verification – ISO 14064-3, Canadian Standards Association, 2012; Instructor – Greenhouse Gas Verification – ISO 14064-3, University of Toronto, 2015 - 2017

Associate Verifier: Jeanna Brown, P.Eng.

Biography: Jeanna Brown is a Professional Engineer with thirteen years of experience in the oil and gas industry. During her previous employment, she focused on drilling engineering and well planning for wells of varying complexity. She has experience with field based drilling engineering/operations, wellsite supervision and exploration projects. More recently, Jeanna’s technical focus concentrated on in-situ oil sands projects and thermal/steam well design. Since joining Brightspot, Jeanna has gained experience working on greenhouse gas verifications for a variety of projects related to oil and gas production and processing, pulp and paper, agriculture and electricity generation. This has included both emission reduction (offset) projects and annual industrial facility reports under the Alberta Specified Gas Emitters Regulation (SGER). Jeanna’s other work in greenhouse gas quantification includes scenario modelling for regulatory compliance, quantification of corporate inventories and consulting on offset project development.

Training: Jeanna received GHG Validation and Verification, ISO 14064-3, training through the University of Toronto in September 2017.

Peer Reviewer: Chris Caners, P.Eng.

Biography: Chris Caners has more than a decade of practice in the energy and environment industry. He has extensive knowledge of energy efficiency, greenhouse gas quantification, assessment and verification; energy and emissions modeling and policy analysis. He has experience leading conservation potential assessments, energy audits, and conservation program planning and design efforts. He recently directed an assessment of energy efficiency potential for a unique electrical distribution system in Canada; he also led a detailed natural gas conservation potential study in Ontario.

Chris has audited dozens of facilities and facility level emission reports (conventional and unconventional oil and gas extraction, processing and transmission, cogeneration, power generation and mining) and energy efficiency and emission reductions projects across Canada, including anaerobic wastewater treatment, commercial building efficiency, acid gas injection, enhanced oil recovery, wind energy, aerobic composting and landfill gas.

Training: Greenhouse Gas Verification – ISO 14064-3, Canadian Standards Association


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3.3 Schedule Provide a list or table of verification activities and dates. Indicate when the verification was completed.

Verification Kickoff Meeting November 28, 2017

Draft Verification Plan December 4, 2017

Site Visit December 4-5, 2017

Supplementary Information Request July 16, 2018

Draft Verification Report July 17, 2018

Final Verification Report August 22, 2018

4.0 Results Add introduction to results section here, if desired.

The verification results are presented in the following five subsections. Subsections 4.1 – 4.3 present the results of the verification procedures for the data integrity (4.1), Quantification Methodologies and Quantification (4.2), and Boundary Conditions and Activity Data (4.3).

4.1 Assessment of Internal Data Management and Controls Provide a summary the information system(s) and its controls for sources of potential errors. Include information on the selection and management of data, process for collecting and consolidating data, data accuracy systems, design and maintenance of the GHG system, the systems and processes that support the GHG information system and results from previous assessments if applicable.

The Project’s GHG quantification is primarily performed in an Excel spreadsheet: “IA Projects Master Calculator_2016-2017_Final For Verifier_June 13, 2018.xlsx”. All data required to quantify emissions reductions for the Project is either manually transcribed into these spreadsheets or electronically transferred from other spreadsheets. The final calculated quantities from this spreadsheet are transferred into the Offset Project Report. Data validation is completed before information is transferred; therefore, there are no active data controls in this document.

All activity data are either metered or referenced from third party data. Meters are maintained on a preventative maintenance program, including periodic calibration. Calibration records are filed on-site.

The Responsible Party maintains an Offset Project Plan (OPP) and produces an Offset Project Report (OPR), which document the emission sources, processes for collecting GHG activity data, equations applied to quantify emissions reduction, calculation assumptions, meter calibration procedure and schedule, the averaging method applied to quantification, and a discussion of GHG data management.

Findings from Previous Verification

There were no unresolved discrepancies identified in the previous verification.


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Results of Verification Procedures

There were three verification procedures completed to test data integrity. The results of these procedures are provided in the following table.

Table 2: Findings of Data Integrity Verification Procedures

GHG Report Element

Verification Procedures Verification Findings

Activity data and emission factor data integrity

Controls test: Analyze all metered data for abnormal data (zeros, missing data, values outside range).

Metered data was reviewed and evaluated for anomalies such as zeros, missing data points, values outside range, etc.

No discrepancies were detected in the activity data.

Substantive test: Recalculate the complete emission reduction using original data.

The recalculated emission reduction matched the quantity asserted by the Responsible Party. It is therefore a reasonable conclusion that data integrity has been maintained from points of metering through reporting.

No discrepancies were detected in the accuracy of the emission reduction quantification.

Transcription of final emission reduction into Offset Project Report

Substantive test: Compare the final emission reduction quantity reported by the Responsible Party to the quantity reported in the Offset Project Report. Also, compare these quantities to the recalculated quantity in previous verification procedures.

Values reported in the Offset Project Report matches the values quantified by the Responsible Party.

No discrepancies were detected in the transcription of values in the Offset Project Report.

4.2 Assessment of GHG Data and Information Provide a summary of the information found during the verification of the GHG data and a summary of the GHG Assertion that was assessed.

For Facilities: Confirm that the quantification methodologies that were used in the compliance report are the same as those reported in the BEIA.

For Offset Projects: Confirm that the quantification methodologies that were used by the project proponent are the same as those described in the project plan. Indicate which quantification methodologies were used by the project proponent.


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The GHG information consists of the activity data applied to quantify emissions reductions, the source documentation for the activity data, the information in the Offset Project Plan, as described in the previous section of this report, and the documentation supporting the boundary, methodologies, meter calibration, and emission factors.

Table 3: Findings of GHG Data and Information Verification Procedures

GHG Report Element


Verification Findings

Quantification Data

Air compressor equipment nameplate capacity

Substantive test: Observe the nameplate information for the air compressors during the site visit.

The air compressor nameplate specifications were noted during the site visit. The nameplate specifications were found to match the capacities used in the quantification.

No discrepancies were detected in the air compressor nameplate capacities used in the quantification.

Metered compressed air volume

Controls test: Review meter calibration reports to determine if the meter maintenance program is operating effectively.

The meter calibration reports were reviewed and were found to be complete.

No discrepancies were detected in the meter calibration reports.

Methane concentration in gas

Substantive test: Analyze gas compositions for significant fluctuations or abnormal gas concentrations. Confirm the accurate transcription of the gas analysis into the emission reduction calculation.

A change in gas composition occurred at the Strathmore Phase 1 facility during the reporting period. In August 2017, the Facility began received a richer gas supply from a third party which significantly changed the methane concentration in the gas stream, from 0.9759 (November 7, 2016 gas analysis) to 0.7981 (October 13, 2017 gas analysis). The gas composition used in the quantification was updated to reflect the new gas analysis from August 1, 2017 forward.

Transcription of the gas analysis to the emission reduction calculation was completed accurately.

No discrepancies were detected in the gas composition analyses used in the quantification.


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GHG Report Element



Substantive test: Review completeness of gas composition data.

Gas composition data was reviewed and found to be complete.

No discrepancies were detected in the completeness of gas composition data.

Reference density of methane at STP conditions

Substantive test: Compare the density of methane applied in the calculations to the reference value provided in the relevant reference documents.

The Responsible Party used a value of 0.6797 kg/m3 for the density of methane at STP conditions (referenced from http://encyclopedia.airliquide.com)

No discrepancies were detected in the reference density of methane at STP conditions used in the quantification.


Substantive test: Compare the Alberta electricity grid factor applied in the calculations to the reference value provided in the relevant reference documents.

The Alberta electricity grid factor applied in the calculations was taken from the Carbon Offset Emission Factors Handbook and was confirmed to match the reference value.

No discrepancies were detected in the electricity grid factor used in the quantification.

Emission Quantification and Reporting

Application of the approved quantification protocol

Controls test: Compare the methodologies described in the Responsible Party’s Offset Project Plan to the methodologies described in the approved quantification protocol.

The verification team compared the methods described in the Offset Project Plan to the methods described in the approved Quantification Protocol.

The quantification methods described in the Responsible Party’s Offset Project Plan adhere to the methods described in the approved Quantification Protocol.

No discrepancies were detected in the methodologies described in the Offset Project Plan.


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GHG Report Element



Substantive test: Recalculate the emission reduction using original metered data and methods described in the approved quantification protocol.

The independent recalculation of the emission reduction resulted in the same emission reduction quantity asserted by the Responsible Party. Therefore, the approved Protocol quantification methods were applied in the Responsible Party’s emission reduction quantification.

No discrepancies were detected in the application of the approved quantification protocol.

Quantification of emission reduction

Substantive test: Recalculate the emission reduction using original metered data.

The independent recalculation of the emission reduction resulted in the same emission reduction quantity asserted by the Responsible Party. Therefore, the Verification Team concluded that no arithmetic or calculation errors were made by the Responsible Party in the emission reduction quantification.

No discrepancies were detected in the recalculation of the emission reduction quantification.

4.3 Assessment against Criteria Provide a description of how eligibility criteria is met or not met.

For Offset Project: Complete Table 1 to indicate if the GHG Assertion conforms to the Regulation and Standard for Greenhouse Gas Emission Offset Project Developers eligibility criteria.

For Facilities: Delete Table 1 and Indicate if verification criteria are met or not met and explain.


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Table 4: Findings of Criteria Verification Procedures

GHG Report Element


Protocol Applicability Requirements

Functional equivalence must be demonstrated

Substantive test: Observe operations and interview operations staff during site visit to determine level of service provided by project implementation.

During the site visit, the verification team observed the instrument air system and found that an equivalent level of service is provided.

Site staff indicated that following the commissioning stage, the system has worked well. Ongoing maintenance is performed during regular maintenance of the full facility. They reported that the instrument air system requires less maintenance than the instrument gas system that was replaced as part of the project.

No discrepancies detected.

Project must be a conversion (not a greenfield or end-of-life replacement)

Substantive test: Observe operations during site visit to determine if project was implemented as a retrofit and not as an end-of-life replacement.

During the site visit, the verification team confirmed that the project was implemented as a retrofit and not as an end-of-life replacement.


An inventory of devices must be maintained

Substantive test: Observe devices during site visit and compare against project inventory to evaluate completeness.

The installed equipment was confirmed against the Responsible Party’s inventory during the site visit.


Demonstrate compliance with Section 8.7 of Directive 60 related to fugitive emissions management prior to project implementation

Control test: Review the project developer’s management system for leak detection and repair to determine if system is complete for all sites and has been maintained through the reporting period.

The Responsible Party maintains documentation of the ongoing leak detection and repair that is conducted for the instrument air site. Leaks are systematically identified and scheduled for repair.

The leak detection and repair report was reviewed; no leaks were detected.



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GHG Report Element


Protocol may be applied to chemical injection pumps.

Not applicable for this project.

Not applicable.

The project must meet the requirements of the Alberta Offset System

Substantive test: Evaluate the project developer’s evidence regarding the general requirements of the Alberta Offset System.

Occurs in Alberta – The project site is located within Alberta, as confirmed by the site visit and project documentation.

Actions not otherwise required by law – confirmed that the site is not defined as a “regulated facility” under the Specified Gas Emitters Regulation. No other regulatory requirements were found to apply to the project activity for this site.

Actions taken on or after January 1, 2002 – commissioning of the instrument air system occurred after this date, as confirmed by project documents and inquiries of site operations staff.

Real, demonstrable, quantifiable – the verification procedures confirmed that the emission reduction in the assertion meet these requirements. The specific verification procedures supporting this conclusion include observation during the site visit, review of supporting meter calibration reports and documentation, and the recalculation of the emission reduction.


Project developer must establish the ownership of the emission reduction for each site within the aggregated project

Substantive test: Review ownership documents for each project site within the aggregated project.

Ember Resources owns 100% of the Strathmore 09-27-024-25W5 facility and is the sole owner of the emission offsets from this project.

Ownership documentation was reviewed by the verification team.



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GHG Report Element


Protocol Flexibility

Site specific emission factors may be applied


Baseline and project metering may be extended beyond one year.


Use of instrument counts and vent rates may be used to estimate baseline emissions.


Flaring may be used to destroy captured vent gas


Implementation of instrument air conversion at multiple facilities.



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Table 5: Offset Criteria Assessment

Offset Eligibility Criteria

Assessment

Reduction or sequestration occurs in Alberta

The project site is located within Alberta, as confirmed by the site visit and project documentation.

Result from actions not required by Law at the time the action is taken

The project activity is not required by municipal, provincial or federal regulations or directives.

Result from Actions taken on or after January 1, 2002 and occur on or after January 1, 2002

Commissioning of the instrument air system occurred after this date, as confirmed by project documents and inquiries of site operations staff.

Reduction or sequestrations is real and demonstrable

The emission reduction was demonstrated through measurement and estimation of data required for the quantification. The GHG information presented to the verification team included sufficient and appropriate evidence to substantiate conformance with the Protocol Applicability Requirements and to substantiate the quantification data.

Quantifiable and measurable

The emission reduction was demonstrated through measurement and estimation of data required for the quantification. This data was substantiated by sufficient and appropriate evidence. Table 3 of this report presents the findings of the evaluation of each variable required for the emission reduction quantification.

Verified by a third party verifier that meets the requirements in Part 1 for the Standard for Validation, Verification and Audit.

Brightspot Climate Inc. is an independent third-party verifier that meets the requirements outlined in Section 1 of the Standard for Validation, Verification and Audit. The Lead Verifier and Designated Signing Authority, Aaron Schroeder, is a Professional Engineer and has extensive experience quantifying and verifying greenhouse gas emissions, satisfying all sixteen subject matter areas defined in the ISO 14064-3 Standard.


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4.4 Evaluation of the GHG Assertion The verification assessment is that the GHG Assertion meets the requirements of the Carbon Competitiveness Incentive Regulation

Provide an assessment of the evidence collected during the verification. Determine if the data and information available support the GHG assertion. Provide a conclusion on whether the assertion meets the materiality requirements and the level of assurance agreed to at the beginning of the verification process.

The results of each verification procedure are provided in the preceding three subsections (4.1 – 4.3). Sufficient and appropriate evidence was collected through the verification procedures to reach the verification conclusion at a reasonable level of assurance, which is provided in the Verification Statement.

The data and GHG information provided by the Responsible Party is sufficient to support the GHG assertion.

There were no material or immaterial discrepancies detected in the final GHG assertion.

4.5 Summary of Findings Provide a summary of material and immaterial discrepancies expressed in tonnes and as net and absolute error in Table 2. Include whether the discrepancy was an understatement or an overstatement.

Include a more detailed description and log of results in Appendix C the “Issues Log”. This log will include both resolved and unresolved issues from the verification. Unresolved issues should be brought forward to Table 2.


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Table 6: Summary of Findings

Number the finding with the year and provide a unique # for each finding. Note: A detailed description of all material and immaterial findings should be provided in Table 3 of Appendix C. Provide only a summary statement (1-4 sentences) for each unresolved immaterial finding and each material finding (resolved or unresolved). If the finding is a resolved material finding, then put the tonnes net and absolute in the summary description column and indicate n/a in the net and absolute columns. Do not include the tonnes in the total error calculation. Indicate the type of error (qualitative or quantitative). Indicate the Source Category (for facilities) or the Source/Sink (for offsets). Indicate if the finding is an understatement or overstatement. Provide both net and absolute error in tonnes of CO2 eq and as a % of the assertion. Provide the total net error and the total absolute error in tonnes of CO2 eq and as a % of the assertion.

Result Type Summary Description of Finding Source Category or Source/Sink

Understatement / Overstatement

Tonnes CO2e % net

Tonnes CO2e % absolute


Total Error 0 0


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4.6 Opportunity for Improvement Provide feedback on the data management system and controls, transparency, completeness of the inventory, additions to the quantification methodology document or diagrams, etc. Include positive considerations and observations also.

Identify strengths and weaknesses that may help to improve the report/s for the current facility, sector, and compliance program. Identify ways in which the project/facility could be more easily verified.

Overall, the GHG information was orderly and thoroughly presented.

The quantification spreadsheets were satisfactorily organized and sufficiently transparent to conduct the verification procedures.

Sufficient and appropriate evidence was provided by the Responsible Party to conduct each of the verification procedures.

The Offset Project Plan and Offset Project Report thoroughly document the emission sources, quantification approach, equations, data collection and information controls.

5.0 Closure 5.1 Verification Statement Include the signed verification statement in Appendix D.

Instructions to insert a pdf: 1. Click Insert>Object 2. In the Object dialog box click Create from File and then click Browse. 3. Find the pdf you want to insert then click Insert. 4.Click OK.

For Offset Projects: fill in the sample Verification Statement provided, sign, scan and paste.

For Facilities: paste a signed version of the Verification Statement from the facility compliance form. Include the conclusion on the GHG assertion and any qualification or limitations and the level of assurance.

Provide the verification conclusion in the drop down box below.

The verification conclusion is:

Positive

5.2 Limitation of Liability Include signed Conflict of Interest Checklist in Appendix E.

For Offset Projects: fill in the sample Conflict of Interest Checklist provided, sign, scan and paste.

For Facilities: paste the signed Conflict of Interest Checklist from the facility compliance form.

Insert limitation of liability statement and include information in an Appendix F if applicable.


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5.3 Confirmations Document information confirmed, including any discrepancies or inconsistencies, as per the Confirmations section in the Standard for Greenhouse Gas Verification.

Section 5.1.3 of the Standard for Validation, Verification and Audit document lists seven activities that are beyond the scope of a typical greenhouse gas verification.

Table 7: Confirmation Findings

Confirmation Confirmation Finding

Correct entry of administrative fields such as facility codes and legal locations

The Offset Project Report was reviewed for completeness and accuracy. All facility and legal location information is complete and accurate.

Quantification Methodology document is provided and consists of the required components

The Responsible Party has documented all relevant methodologies, procedures and controls in the Offset Project Plan and the Offset Project Report.

Simplified process flow diagrams and energy diagrams

This requirement is not applicable to this Offset Project.

Fuel usage This requirement is not applicable to Offset Projects.

Additional request items/forms are complete and reasonable justification provided where needed

The Statutory Declaration was reviewed and found to be complete.

N/A is checked on pages in the reporting form that do not apply

This requirement is not applicable to Offset Projects.

Project report information details as required The Responsible Party has prepared an Offset Project Report that meets all the requirements specified in the Standard for Greenhouse Gas Emission Offset Project Developers, Version 2.0, July 2018.

6.0 References Author. Year. Title. (no hyperlinks)

None

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Appendix A: Final Verification Plan and Sampling Plan


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Information to be included in the Verification Plan and Sampling Plan:

Revisions to the sampling plan

Date originally sent to Facility/project

Level of assurance agreed with the facility/project developer

Verification scope

Verification criteria

Amount and type of evidence (qualitative and quantitative) necessary to achieve the agreed level of assurance

Methodologies for determining representative samples

Sampling Plan and Procedures

Risk Assessment: Risks of potential errors, omissions or misrepresentations that are identified throughout the verification process including:

- Details of site visit

-offset/facility boundaries

- Methodologies, emissions factors and conversions used

- Comparability with the approved baseline

- Conformance to the program criteria

- Integrity for the responsible party’s data management system and control (organization chart, GHGH management plan, personnel/consultant training, protocols used, control system documentation, software/program documentation/certifications)

- Greenhouse gas data and information, including the type of evidence collected, verification testing and crosschecking, inventory of emission sources

- Discussion of data management, (measurement, fuel sampling, calibration, consistent use of standard conditions, data storage, procedures to fill missing data; procedures to repair inconsistent data, adjustment of variables and factors)

- Other relevant information

+1 (604) 353-0264 • www.brightspot.co • [email protected]


Instrument Air Conversion Aggregation Projects Verification Plan

December 4, 2017

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Brightspot Climate Inc. – Verification Plan Ember Resources Inc. – Instrument Air Conversion Aggregation Projects

i

Terminology

ISO 14064-2 defines the following terms used in the context of a GHG verification:

GHG Assertion: a declaration or factual and objective statement made by the Responsible

Party.

The Alberta Climate Change Office Standard for Verification1 extends this definition to include

the document that identifies the greenhouse gas emission reduction and/or removals and offset

credits being claimed by the offset project over a defined period of time.

Project: activity or activities that alter the conditions identified in the baseline scenario which

cause greenhouse gas emission reductions or greenhouse gas removal enhancements.

The GHG Assertion subject of this verification is Ember Resources’ Instrument Air Conversion

Aggregation Projects, namely:

• Ember Resources Instrument Air Conversation at Strathmore Phase 1

• Ember Resources Instrument Air Conversion Aggregation Project

• Ember Resources Instrument Air Conversion Aggregation Project Phase 2

Collectively, these three emission reduction projects will be referred to throughout this proposal

as “The Projects”.

ISO 14064-2 defines the following parties associated with the verification:

Responsible Party: person or persons responsible for the provision of the greenhouse gas

assertion and supporting GHG information.

The Responsible Party for this verification is Ember Resources Inc. (Ember Resources).

Intended User: individual or organization identified by those reporting GHG-related information

as being the one who relies on that information to make decisions.

The Intended User for this verification is the Alberta Climate Change Office (ACCO).

Verifier: competent and independent person, or persons, with the responsibility of performing

and reporting on the verification process.

The Verifier for this verification is Brightspot Climate Inc. (Brightspot Climate). The members of

the verification team are provided in section 3 of this document.

1 Standard for Verification, Version 1.0, December 2017. Alberta Climate Change Office.


1

Introduction

This document serves to communicate information between the parties associated with the

independent verification of the Offset Project Reports for the Instrument Air Conversion Aggregation

Projects.

This document contains six sections:

1. The Introduction, which defines the principles by which this verification will be conducted;

2. The Verification, which defines the verification parameters and the GHG inventory principles that

will be tested by the verification. This section also provides information regarding the verification

team and site visit;

3. The Responsible Party Data Management and Controls, which describes the data management

system and control environment implemented by the Responsible Party;

4. Previous GHG Assertions, which describes any modifications to the original project that have

been made since the original Offset Project Plan was developed and any findings from previous

verifications for this Project;

5. The Verification Risk Assessment and Verification Procedures, which describes the risks of

potential errors, omissions or misrepresentations to the overall GHG assertion and the

verification procedures that have been developed to reduce the overall verification risk; and

6. The Sampling Plan, which lists the verification procedures that could apply sampling of the

project data, along with the sampling size, the sampling methodology and justification.

The verification procedures, including the sampling plan and the results of the verification risk

assessment, will be appended to this verification plan in the final verification report.

The Responsible Party developed the Project in accordance with the requirements of the Quantification

Protocol for Instrument Gas to Instrument Air Conversion in Process Control Systems, Version 1.0,

October 2009 (the Protocol).

GHG Quantification Principles

ISO 14064-2 defines six principles that are fundamental to the fair accounting and reporting of GHG

information. The verification procedures will test that these principles have been upheld through the

Responsible Party’s inventory, accounting and reporting processes.

Section 3.2 – 3.6 of ISO 14064-1 defines these principles as follows:

Accuracy: reduce bias and uncertainty as far as practical

Completeness: include all relevant emission sources

Conservativeness: use conservative assumptions, values and procedures to ensure that GHG

emission reductions or removal enhancements are not over-estimated

Consistency: enable meaningful comparisons of reported emissions (from year to year or

between facilities or between companies)


2

Relevance: select GHG sources, sinks and reservoirs, data and quantification methodologies

appropriate to the needs of the intended user

Transparency: disclose sufficient and appropriate GHG information to facilitate verification and

to allow intended users to make decisions with relative confidence


3

Verification

Verification Principles

ISO 14064-3 defines four fundamental principles to conducting a greenhouse gas verification, namely

independence, ethical conduct, fair presentation and due professional care.

Brightspot Climate has implemented processes, including mandatory training for all verification team

members, to ensure the application of these principles for this verification.

Regarding the principle of independence, Brightspot Climate conducted an assessment of threats to

independence prior to initiating this verification. No real or perceived threats to independence were

identified. Brightspot Climate will continue to monitor for threats to independence throughout the

course of this verification. A final “Conflict of Interests Checklist” will be appended to the Verification

Statement.

Verification Parameters

The verification will be conducted according to the parameters defined in the following table:

Table 1: Verification Parameters

Level of Assurance Reasonable assurance

Objectives

• issue a verification statement on whether the GHG assertion is

without material discrepancy;

• issue a verification report that provides details of the verification

activities; and

• complete the “confirmations” activities defined in the Standard for

Verification2, Section 5.1.3.

Criteria

• Climate Change and Emissions Management Act

• Carbon Competiveness Incentive Regulation (255/2017)

• Standard for Greenhouse Gas Emission Offset Project Developers,

Version 1.0, December 2017

• Standard for Verification, Version 1.0, December 2017

• Quantification Protocol for Instrument Gas to Instrument Air

Conversion in Process Control Systems, Version 1.0, October,

2009

2 Standard for Verification, Version 1.0, December 2017, Alberta Climate Change Office.


4

Scope

Project Name: Ember Resources Instrument Air Conversion

Aggregation Project

Ember Resources Instrument Air Conversion

Project Phase 2

Ember Resource Instrument Air Conversion at

Strathmore Phase 1

Geographic Boundary: Natural gas processing and compression

facilities in Ember Resources’ natural gas

network in Central Alberta

Physical Operations: Natural gas processing and compression

Pneumatic devices

Emission Sources: Instrument Air Conversion

• B7: Vented Fuel Gas

• B10: Fuel Extraction and Processing

• P6: Air Compression

IPCC GHGs Emitted: Carbon Dioxide (CO2)

Methane (CH4)

Nitrous Oxide (N2O)

Reporting Period: August 1, 2016 – December 31, 2017

Materiality Quantitative materiality threshold is 5% of asserted greenhouse gas

emission reduction

Preliminary Verification

Schedule

Verification Kickoff Meeting November 28, 2017

Draft Verification Plan December 4, 2017

Site Visit December 4-5, 2017

Draft Verification Report June 15, 2018

Final Verification Report June 30, 2018

Verification Team

Aaron Schroeder, P.Eng., will be the Lead Verifier and Designated Signing Authority for this verification.

His extensive experience quantifying and verifying greenhouse gas emissions satisfies all sixteen subject

matter areas defined in the ISO 14064-3.

Jeanna Brown, P.Eng., will conduct the site visits, complete the verification procedures and prepare the

Verification Report under the supervision of the Lead Verifier.

Chris Caners, P.Eng., will conduct an independent peer review of the verification.

Additional information regarding the qualifications of the verification team will be provided in a

Statement of Qualifications, which will be appended to the Statement of Verification.


5

Site Safety Requirements

Personnel conducting site visits are required to wear personal protective equipment including steel-toed

boots, fire retardant coveralls, hard hat, safety glasses with side shields and gloves. A site orientation

must be completed before entering the site.


6

Responsible Party Data Management and Controls

Data Management Systems

Jamie Callendar, as consultant to the Responsible Party, has the primary responsibility for collecting

GHG information, quantifying the emission reduction and completing required documentation.

The Responsible Party uses an Excel based Emission Reduction Calculator to manage GHG

information and quantify the emission reduction. Table 2, below, describes the data measurement,

estimation and data storage locations for all GHG information used by the Responsible Party to

produce the GHG inventory. The final column in this table describes the data storage location and the

path (intermediate data transfer) prior to use in the GHG inventory.

Table 2: GHG Inventory Data Management

Activity Data Description Measurement Type Data Storage Location / Path

Air compressor nameplate

capacity

Manual reading Calculation spreadsheet

Metered compressed air

volume

Direct metering Metered quantity

>> SCADA system

>> PI system

>> Calculation spreadsheet

Methane concentration in

gas

Third-party analysis Laboratory analysis


Reference density of

methane at STP conditions

Third-party reference Third party reference value


Alberta electricity grid

factor

Alberta Environment

and Parks Emission

Factor Handbook

Emission Factor Handbook value


Control Environment

The Responsible Party’s Offset Project Plan (OPP) describes the processes, procedures and systems

that have been designed and implemented within their quality assurance / quality control framework.

The accuracy and completeness of the documentation of the Responsible Party’s controls will be

reviewed through the course of the verification.

The following processes, procedures and systems have been employed by the Responsible Party:

• Quantification is based on direct metering and measurement.

• The project developer has implemented a management system for leak detection and repair.

• The Responsible Party has implemented a meter maintenance program that includes periodic

meter calibration.

• Gas composition analysis is performed by an independent, third-party laboratory.


7

• Data is transferred electronically between systems where possible to reduce transcription

errors.

• The Responsible Party has implemented a record retention system that meets the requirements

of the Regulation.

• The Offset Project Plan (OPP) is reviewed annually for accuracy, completeness, consistency,

relevance and transparency. The OPP documents:

o Project boundaries

o Project processes

o Emission sources

o Changes made to the project boundaries, operations or emission sources

o Activity data used to quantify emissions

o Emission quantification equations and other methods for deriving values required for the

quantification of the emission reduction

o Emission factors and references

o Meter maintenance processes

o Data management

o Data quality controls and procedures


8

Previous GHG Assertions

Changes to Operations and Boundaries

This is the second year that Brightspot Climate has provided verification services for the Projects.

A number of changes have been made since the original Offset Project Plans were produced:

• Baseline emissions associated with fossil fuel extraction and processing (SSR B10) were

originally excluded but have been included in the emission reduction quantification since

January 16, 2015 in accordance with the Protocol.

• Project emissions associated with electricity usage to operate the instrument air compressors

(SSR P6) were originally excluded but have been included in the emission reduction

quantification since June 11, 2013 to meet new requirements from Alberta Environment and

Parks (AEP).

• The Global Warming Potential for methane was updated beginning in January 1, 2014, in

accordance with guidance from AEP.

• The data historian for instrument air volume data was changed from “PI” to “SCADAvantage”

beginning in January 2015.

Findings from Previous Verifications

There were no unresolved discrepancies described in the previous verification report (the previous

verification was conducted by Brightspot Climate).


9

Verification Risk Assessment and Verification Procedures

Verification risk is defined as the risk of an incorrect verification conclusion. It can be calculated as the

product of

1) The Facility’s inherent risks;

2) The Responsible Party’s control risks; and

3) The detection risks associated with the auditor’s audit procedures.

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The verifier cannot affect the inherent risk or the control risk. Therefore, to reduce the overall verification

risk and reach the agreed level of assurance (defined in the verification scope), the verifier must design

verification procedures that reduce the detection risk.

The Verification Risk Assessment was completed prior to issuing the draft version of this document.

Each inherent and control risk is provided with the risk evaluation (high/medium/low). The risk analysis

of inherent and control risks considers both the magnitude of the activity data or inventory component

on the overall GHG assertion as well as the probability that the risk will result in a discrepancy, as

assessed by the verifier.

The verification procedures define the amount and type of evidence required to achieve a reasonable

level of assurance. All verification procedures must be completed and the associated evidence must be

available to reach an unqualified verification conclusion.

Several verification procedures will be completed during the site visit, as described in the following

table.


10

Table 3: Verification Risk Assessment Summary

Activity Data /

Inventory

Component

Inherent Risk Control Risk Max

Detection

Risk

Designed

Detection

Risk

Description of Verification

Procedure

Verification

Risk

PROTOCOL APPLICABILITY REQUIREMENTS

Functional

equivalence must be

demonstrated

Relevance (high)

Level of service may

have changed

between the baseline

and project

conditions.

The Responsible

Party does not have a

control specifically

designed to address

this inherent risk.

Low Low Substantive test: Observe

operations and interview

operations staff during site visit

to determine level of service

provided by project

implementation.

Low

Project must be a

conversion (not a

greenfield or end-of-

life replacement)

Relevance (high)

Project may have

been implemented at

greenfield sites or as

end-of-life

replacement.

The Responsible



designed to address

this inherent risk.

Low Low Substantive test: Observe

operations during site visit to

determine if projects were

implemented as a retrofit and

not as an end-of-life

replacement.

Low

An inventory of

devices must be

maintained

Completeness

(medium)

The inventory of

devices may be

incomplete.

The Responsible



designed to address

this inherent risk.

Medium Medium Substantive test: Observe

devices during site visit and

compare against project

inventory to evaluate

completeness.

Medium


11

Activity Data /

Inventory

Component


Detection

Risk

Designed

Detection

Risk


Procedure

Verification

Risk

Demonstrate

compliance with

Section 8.7 of

Directive 60 related to

fugitive emissions

management prior to

project

implementation

Completeness

(medium)

A leak detection and

repair program may

not have been

implemented at all

project sites.

Control: The project

developer has

implemented a

management system

for leak detection and

repair.

Control Risk: This

system may not have

been implemented or

maintained at all

project sites (low).

Medium Medium Control test: Review the project

developer’s management

system for leak detection and

repair to determine if system is

complete for all sites and has

been maintained through the

reporting period.

Low

Protocol may be

applied to chemical

injection pumps.

N/A N/A N/A N/A Not applicable for this project. N/A

The project must

meet the

requirements of the

Alberta Offset System

Relevance (high)

The project may not

have met the

requirements of the

Alberta Offset

System.

The Responsible



designed to address

this inherent risk.

Low Low Substantive test: Evaluate the

project developer’s evidence

regarding the general

requirements of the Alberta

Offset System.

Low


12

Activity Data /

Inventory

Component


Detection

Risk

Designed

Detection

Risk


Procedure

Verification

Risk

Project developer

must establish the

ownership of the

emission reduction for

each site within the

aggregated project

Completeness (high)

Ownership may not

be established with

documentation for all

sites within the

aggregated project.

The Responsible



designed to address

this inherent risk.

Low Low Substantive test: Review

ownership documents for each

project site within the

aggregated project.

Low

PROTOCOL FLEXIBILITY

Site specific emission

factors may be

applied


Baseline and project

metering may be

extended beyond one

year.

Accuracy (medium)

Project metering is

continuous through

the reporting period.

Undetected leaks

may overstate the

emission reduction.

Control: Project

developer has

implemented a leak

detection and repair

program at the

project sites, as

required by the

Protocol.

Control Risk: This

system may not have

been implemented or

maintained at all

project sites (low).

Medium Low See verification procedure

regarding leak detection and

repair in the “Protocol

Applicability Requirements”

section, above.

Low


13

Activity Data /

Inventory

Component


Detection

Risk

Designed

Detection

Risk


Procedure

Verification

Risk

Use of instrument

counts and vent rates

may be used to

estimate baseline

emissions.


Flaring may be used

to destroy captured

vent gas


Implementation of

instrument air

conversion at multiple

facilities.

Completeness

(medium)

The project

aggregates

installations at

multiple project sites.

The data and

documentation may

not be complete for

all sites.

The Responsible



designed to address

this inherent risk.

Medium Low Substantive test: Evaluate the

completeness of the required

data and documentation for all

project sites included in the

aggregated project.

Low


14

Activity Data /

Inventory

Component


Detection

Risk

Designed

Detection

Risk


Procedure

Verification

Risk

QUANTIFICATION DATA

Air compressor

equipment nameplate

capacity

Accuracy (low)

The recorded air

compressor

nameplate capacity

may be inaccurate.

The Responsible



designed to address

this inherent risk.

High Medium Substantive test: Observe the

nameplate information for the

air compressors during the site

visit and review supporting

documentation.

Low

Metered compressed

air volume

Accuracy (high)

The metered

compressed air

volume may be

incorrect if meters are

not properly

maintained.

Control: The

Responsible Party

has implemented a

meter maintenance

program that includes

periodic meter

calibration.

Control Risk: The

maintenance program

may not be operating

effectively (low).

Low Low Controls test: Review meter

calibration reports to determine

if the meter maintenance

program is operating

effectively.

Low


15

Activity Data /

Inventory

Component


Detection

Risk

Designed

Detection

Risk


Procedure

Verification

Risk

Methane

concentration in gas

Accuracy (low)

Reported gas

compositions may not

accurately represent

the gas composition

or may be incorrectly

transcribed into the

emission reduction

calculation.

Control: Gas analysis

is conducted by an

independent lab. An

internal process is

used to validate

results.

Control Risk:

Validation process

may not be properly

implemented or

transcription errors

may be introduced

(low).

High Low Substantive test: Analyze gas

compositions for significant

fluctuations or abnormal gas

concentrations. Confirm the

accurate transcription of the

gas analysis into the emission

reduction calculation.

Low

Completeness (low)

The gas compositions

may not include a

valid gas composition

for each period at the

required frequency.

The Responsible



designed to address

this inherent risk.

High Medium Substantive test: Review

completeness of gas

composition data.

Low


16

Activity Data /

Inventory

Component


Detection

Risk

Designed

Detection

Risk


Procedure

Verification

Risk

Reference density of

methane at STP

conditions

Accuracy (low)

The density of

methane applied in

the calculation may

not represent the

density at STP

conditions.

The Responsible



designed to address

this inherent risk.

High Low Substantive test: Compare the

density of methane applied in

the calculations to the

reference value provided in the

relevant reference documents.

Low

Alberta electricity grid

factor

Accuracy (low)

The Alberta electricity

grid factor applied in

the calculation may

be incorrect.

The Responsible



designed to address

this inherent risk.

High Low Substantive test: Compare the


applied in the calculations to

the reference value provided in

the relevant reference

documents.

Low


17

Activity Data /

Inventory

Component


Detection

Risk

Designed

Detection

Risk


Procedure

Verification

Risk

EMISSION REDUCTION QUANTIFICATION

Application of the

approved

quantification protocol

Accuracy (high)

The project developer

may not have

implemented

approved

quantification

methodologies or

applied additional

methodologies.

Control: Responsible

Party has developed

an Offset Project Plan

that is intended to

conform to the

requirements of the

approved

quantification

protocol.

Control Risk: The

protocol requirements

may not have been

implemented correctly

(medium).

Medium Low Controls test: Compare the

methodologies described in the

Responsible Party’s Offset

Project Plan to the

methodologies described in the

approved quantification

protocol.

Low

Substantive test: Recalculate

the emission reduction using

original metered data and

methods described in the

approved quantification

protocol.

Low


18

Activity Data /

Inventory

Component


Detection

Risk

Designed

Detection

Risk


Procedure

Verification

Risk

Quantification of

emission reduction

Accuracy (high)

Emission reduction

calculation may

contain arithmetic

errors.

The Responsible



designed to address

this inherent risk.

Low Low Substantive test: Recalculate

the emission reduction using

original metered data.

Low

DATA INTEGRITY

Activity data and

emission factor data

integrity

Accuracy (high)

Data may not have

been accurately

transferred between

electronic systems

and calculation

sheets.

Control: The

Responsible Party

uses electronic data

transfers whenever

possible to maintain

data integrity.

Control Risk:

Electronic data

transfers may result in

errors or may not be

available for all data

(medium).

Low Low Controls test: Analyze all

metered data for abnormal

data (zeros, missing data,

values outside range).

Low

Substantive test: Recalculate

the complete emission

reduction using original data.

Low


19

Activity Data /

Inventory

Component


Detection

Risk

Designed

Detection

Risk


Procedure

Verification

Risk

Transcription of final

emission reduction

into Offset Project

Reports

Accuracy (high)

Final emission

reduction may not

have been transcribed

accurately from

calculation

spreadsheets into the

Offset Project

Reports.

The Responsible



designed to address

this inherent risk.

Low Low Substantive test: Compare the

final emission reduction

quantity reported by the

Responsible Party to the

quantity reported in the Offset

Project Reports. Also, compare

these quantities to the

recalculated quantity in

previous verification

procedures.

Low


20

Sampling Plan

The verification procedures that could apply sampling of the project data are listed in the following table.

The sampling size, the sampling methodology and their respective justifications are also described in the following table.

Table 4: Sampling Plan

Activity Data /

Inventory

Component

Designed

Detection

Risk


Procedure

Sampling Methodology and

Justification

Sample Size

Air compressor

equipment

nameplate capacity

Low Substantive test: Observe the

nameplate information for the air

compressors during the site visit

and review supporting

documentation.

Four of the nine subproject sites

were visited, including minimum

one site from each of the three

registered projects, and minimum

one site from each majority

working interest operator.

Supporting documentation for all

sites was reviewed.

Site Visits:

• 08-34-29-22W4

• 01-24-28-24W4

• 10-07-28-23W4

• 09-27-24-25W4

Metered

compressed air

volume

Low Controls test: Review meter

calibration reports to determine if

the meter maintenance program is

operating effectively.

Review of full dataset has lower

detection risk than sampling.

Annual calibration for each of the

nine sites.

Methane

concentration in

gas

Low Substantive test: Analyze gas

compositions for significant

fluctuations or abnormal gas

concentrations. Confirm the

accurate transcription of the gas

analysis into the emission reduction

calculation.

There is only one sample per site

per year. Review of full dataset has

lower detection risk than sampling.

Annual sample for each of the nine

sites.


21

Activity Data /

Inventory

Component

Designed

Detection

Risk


Procedure

Sampling Methodology and

Justification

Sample Size

Methane

concentration in

gas

Low Substantive test: Review

completeness of gas composition

data.

There is only one sample per site.

Review of full dataset has lower

detection risk than sampling.

Annual sample for each of the nine

sites.

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Appendix B: Statement of Qualifications


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Statement of Qualifications

Offset Report

Project Name Offset Project ID

Ember Resources

Instrument Air Conversion at

Strathmore, Phase 1 1665-4576

Reporting Company Legal

Name Report Type

Reporting

Period


Offset Report

from

August 1, 2016

– December

31, 2017

to

Signature of Third Party Verifier

I

, Aaron Schroeder

(Third Party Verifier), meet or exceed the qualifications of

third party

Third-party verifiers described in Section 29 of the Carbon Competitiveness Incentive Regulation.

Verifying Company Name

Brightspot Climate Inc. Per:

Signature of Third Party

Verifier Date

Training Received Under ISO 14064 Part 3

• Greenhouse Gas Verification – ISO 14064-3, Canadian Standards Association, 2012;

• Instructor – Greenhouse Gas Verification – ISO 14064-3, University of Toronto, 2015 – 2018

First Name Last Name

Aaron

Schroeder

Professional Designation E-mail Address Phone Number

Professional Engineer

[email protected]

(604) 353-0264

Lead Verifier

� Same as third party

verifier??




Peer Reviewer


Chris Caners

E-mail Address Phone Number

[email protected] (647) 468-4332


• Greenhouse Gas Verification – ISO 14064-3, Canadian Standards Association, 2008

Aaron Schroeder

August 22, 2018

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Appendix C: Findings and Issues


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Table 8: Detailed Findings and Issues Log

Number the issue with the year and provide a unique # for the issue. If the issue resolved during the verification, indicate that in the resolution column. If the issue is not resolved during the verification, or if the issue was material (whether resolved or not) record it as a finding in Table 2 and provide a cross reference to the finding # in the resolution column. Describe the issues investigated. State the verification criteria that are not met. Provide a description of how it is not met and provide the evidence. Indicate the Source Category (for facilities) or the Source/Sink (for offsets). Indicate if the finding is an understatement or overstatement. Summarize information between verifier and client. Provide a conclusion including % discrepancy, if applicable.

Item (YR-##)

Description of the Issues Investigated During the Verification

Summary of information exchanged between Verifier and Responsible Party

Resolution Conclusion


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Appendix D: Statement of Verification


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Statement of Verification Associated SGER Submission

Offset Project Protocol Project ID #

Ember Resources Instrument Air Conversion at Strathmore Phase 1

Quantification Protocol for Instrument Gas to Instrument Air Conversions in Process Control Systems, Version 1.0, October 2009

1665-4576

Project Developer Serial Range Start Report Period

Ember Resources Inc. TBD


Serial Range End

TBD

Statement of Verification GHG Assertion

Value Units

Total Baseline Emissions 356 tonnes CO2e

Total Project Emissions 1 tonnes CO2e

Other 0 tonnes CO2e

Net Reductions 355 tonnes CO2e

Statement of Assertion

The Responsible Party’s GHG Assertion is comprised of the Offset Project Plan, Offset Project Report and supporting documentation.

The GHG Assertion covers the reporting period August 1, 2016 to December 31, 2017 and states an emission reduction and removal claim of 355 tonnes CO2e over this period.

The emission reduction and removal claim consists of 2016 and 2017 vintage credits.


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Responsibilities of Project Developer and Third Party Verifier

Our responsibility as the Verifier is to express an opinion as to whether the GHG Assertion is materially correct, in accordance with approved Protocol, the Carbon Competitiveness Incentive Regulation (the “Regulation”), and the Alberta Climate Change Office – Standard for Greenhouse Gas Emission Offset Project Developers, Version 2.0, July 2018.

We completed our review in accordance with the ISO 14064 Part 3: Greenhouse Gases: Specification with Guidance for the Validation and Verification of Greenhouse Gas Assertions (ISO, 2006). As such, we planned and performed our work in order to provide positive, but not absolute assurance with respect to the GHG Assertion.

The verification procedures that were performed through the course of the verification were developed based on the results of a risk assessment that was completed during the verification planning stage. These verification procedures are described in the Verification Plan. Certain verification procedures included data sampling. The sampling type, sample size and the justification for the planned sampling type and size are detailed in a Sampling Plan, which is included in the Verification Plan.

Conclusion

I believe our work provides a reasonable basis for my conclusion.

There were no unresolved misstatements in the final GHG Assertion.

Based on our review, it is my opinion at a reasonable level of assurance that the GHG Assertion is materially correct and presented fairly in accordance with the relevant criteria.

Signature of Third Party Verifier Verifying Company Name


Signature of Third Party Verifier Date:


Aaron Schroeder


Professional Engineer [email protected] (604)353-0264

Aaron Schroeder

August 22, 218

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Appendix E: Conflict of Interest Checklist


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Conflict of Interest Checklist Associated SGER Submission Offset Project Protocol

Ember Resources Instrument Air Conversion at Strathmore, Phase 1

Quantification Protocol for Instrument Gas to Instrument Air Conversions in Process Control Systems, Version 1.0, October 2009

Project Developer Report Type Report Period

Ember Resources Inc. Offset Report


Checklist Respond either "True" or "False" to each of the following statements:

1. The relationship between my firm and this reporting company poses

unacceptable threat to or compromises the impartiality of my firm.

False

2. The finances and sources of income of my firm compromise the impartiality of

my firm.

False

3. The personnel my firm has scheduled to participate in the verification may have

an actual or potential conflict of interest.

False

4. My firm participated in some manner in the development or completion of the

associated offset submission for this reporting company.

False

5. My firm provided greenhouse gas consultancy services to this reporting

company.

False

6. My firm will use personnel that have, are, or will be engaged or previously

employed by the reporting company.

False

7. My firm will outsource the Statement of Verification for the associated offset

submission.

False

8. My firm offers products or services that pose an unacceptable risk to impartiality.

False

Important: If you have checked "True" to any of the above, you may not fulfill the "independence" requirement for third party verifiers. Please contact Alberta Environment and Parks for further instruction. If the potential conflict of interest is a sufficient threat to impartiality (perceived or actual), or cannot be effectively managed, you Third Party Verification Report will not be acceptable to Alberta Environment and Parks.



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I , Aaron Schroeder (Third Party Verifier), have personally examined and am familiar

with the information contained in this Conflict-of Interest Checklist, and can demonstrate freedom from any conflict of interest related to the reporting company for which the verification was performed. I hereby warrant that the information submitted in this Conflict-of Interest Checklist is true, accurate and complete to the best of my knowledge, and that all matters affecting the validity of this Conflict-of-Interest Checklist have been fully disclosed. Impartiality shall be monitored over the duration of the verification and any identified actual or potential conflict-of-interest situations will be communicated to AEP directly.

Verifying Company Name



Date:


Aaron Schroeder Professional Designation E-mail Address Phone Number

Professional Engineer [email protected] (604) 353-0264

August 22, 2018

Aaron Schroeder

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Appendix F: Supplemental Diagrams/Tables/Figures


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Table 8: Supporting Documentation Reviewed

File Name Description

Ember IA SM1 Offset Project Plan_Aug 1 2018_Final.pdf

Offset Project Plan

IA Projects Master Calculator_2016-2017_Final For Verifier_June 13, 2018.xlsx

Emission reduction calculation worksheet

SM1 IA_ProjectReportForm_Final for Verifier_July 18, 2018.docx

Offset Project Report

9-27-24-25w4m 0662999 June 9 2017.xlsx Calibration report for the meter measuring the volume of compressed air consumed at the project site

09-27-024-25-W4 - 2017-10-13 - GAS^-SG7209V1-2017-10-26-21-55.pdf

Gas analysis laboratory report for the project site

Strathmore 09-27-024-25W4 Air Compressor Drawings.pdf

Facility drawing indicating the air compressor nameplate specification for the project site

Strathmore 09-27 Inspection.pdf Leak Detection and Repair survey report for the project site


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Limitation of Liability

This report is intended for the responsible party and the intended user as defined in the attached verification report. The sole intention of the report is to verify the GHG assertion made by the responsible party named in the report and is not intended to provide assurance of any kind for any purpose other than for reporting under the GHG program as defined in the scope of the attached report.

Brightspot Climate disclaims liability for use by any other party and for any other purpose.

verification report for: proponent: prepared for: versionfor facilities: description of compliance...

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